UT/2021/000157 - [2024] UKUT 00110 (TCC)
Upper Tribunal Tax and Chancery Chamber

UT/2021/000157 - [2024] UKUT 00110 (TCC)

Fecha: 27-Feb-2024

Heading

Neutral Citation: [2024] UKUT 00110 (TCC)

Case Number: UT/2021/000157

UPPER TRIBUNAL
(Tax and Chancery Chamber)

Rolls Building, London

CAPTAL GAINS TAX – whether FTT erred in concluding taxpayer’s transfer of the beneficial interest in distribution rights in company (where the company’s articles did not provide for transfer of those rights) was a disposal – no – appeal dismissed

Heard on: 27 February 2024

Judgment date: 01 May 2024

Before

JUDGE SWAMI RAGHAVAN

JUDGE VIMAL TILAKAPALA

Between

JOHN TENCONI

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: The Appellant

For the Respondents: Stephen Donnelly, Counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION